Legal

Sales Disclaimer

Electronic communication including emails and other transmitted documents ("Communication") may have been prepared by sales functions ("Sales") within GrupoFinanciere or one of its affiliates (collectively "GrupoFinanciere"), and may not have been produced, reviewed or edited by GrupoFinanciere's research department ("Research"). Any opinions expressed in Sales & Communications are those of the author or individual sender ("Author") and may differ from the opinions expressed by other GrupoFinanciere departments, including Research.

These Communications are intended for the personal use of the recipient and do not constitute an offer, a recommendation or a solicitation to enter into, or otherwise purchase or sell, any transaction or security, or to participate in any particular transaction strategy unless they are expressly referenced as such content. These Communicationss, and the information contained therein, do not constitute the provision of investment advice unless they are expressly referenced as such advice. These Communicationss are for the general information of our clients and are a general solicitation of business.

Sales is subject to additional potential conflicts of interest which Research does not face. GrupoFinancieremay engage in transactions in a manner inconsistent with the views discussed in a Communications. GrupoFinancieretrades or may trade as principal in the instruments and may have proprietary positions in the instruments discussed in a Communications. GrupoFinancieremay make a market in the instruments discussed therein; and the Author may know the nature of such trading positions and strategies. Sales personnel are compensated in part based on the volume of transactions effected by them.

Assumptions, estimates and opinions expressed constitute the Author's judgment as of the date of the Communications and are subject to change without notice. Past performance is not necessarily indicative of future results. The Communicationss are based upon information that GrupoFinanciereconsiders reliable as of the date hereof, but GrupoFinancieredoes not represent that it is accurate and complete.

Certain transactions or securities mentioned in a Communications give rise to substantial risk, including currency and volatility risk, and are not suitable for all investors. Communicationss may be intended for institutional customers or accredited investors only and may be furnished for informational purposes only. GrupoFinancieretransacts business with counterparties on an arm's length basis and on the assumption that each counterparty is sophisticated and capable of independently evaluating the merits and risks of each transaction and that the counterparty is making an independent decision regarding any transaction.

Online Privacy Policy

Privacy Principles

Your privacy is important to us. This Online Privacy Policy explains how we collect, share, use and protect your personal information when you visit or use this and other online services offered by GrupoFinanciere that link to or reference this policy (collectively, our "online services"). Please note, however, that this Online Privacy Policy is not an exclusive statement of our privacy principles across all products and services. Other privacy principles or policies may apply depending on the financial products or services you obtain from us, or the jurisdiction in which we are doing business with you. You can access many of these policies using the links at the bottom of this page.

We protect your information.

We take our responsibility to protect the privacy and confidentiality of your information, including personal information, very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal standards to secure such information from unauthorized access and use, alteration and destruction. We hold our employees accountable for complying with relevant policies, procedures, rules and regulations concerning the privacy and confidentiality of information.

We endeavor to collect, use and maintain client information only for appropriate purposes.

The types of personal information we may collect from you when you visit or use our online services include your name, email address, mailing address, telephone number(s), account numbers, limited location information (for example, a zip code to help you find a GrupoFinanciere office near you), user name and password. We may also collect payment card information, Social Security numbers, driver's license numbers (or comparable) when you provide such information while using our online services and where we believe it is reasonably required for ordinary business purposes.

In addition to the personal information described above, we may collect certain information about your use of our online services. For example, we may capture the IP address of the device you use to connect to the online service, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. As explained in more detail in our Cookies Policy, we or our third-party partners may use cookies (as well as web beacons or other technologies) to collect and store this and other information about your visit to, or use of, our online services. We may later associate the usage and other information we collect online with personal information about you, as permitted or required by law.

We may also collect information about you from additional online and offline sources including commercially available third-party sources, such as credit reporting agencies. We may combine this information with the personal and other information we have collected about you under this Online Privacy Policy.

We may use the information we collect from you to help us deliver our online services; to administer, evaluate and improve our business (including developing new products and services, improving existing products and services, performing data analytics, and performing accounting, auditing and other internal functions); manage our risks; market our services and products; and to comply with and enforce applicable laws and regulations, relevant industry standards, contractual obligations and our policies. We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual clients) for various business purposes, where permissible under applicable laws and regulations.

We respect and protect your privacy even when you're on the go.

For your convenience, GrupoFinanciere offers you the ability to access some of our products and services through mobile applications and mobile-optimized websites. When you interact with us through your mobile device, we may collect information such as unique device identifiers, your screen resolution and other device settings, information about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information, such as precise geolocation information.

We share personal information with affiliates and with others when we believe it will enhance the services and products we can provide to you or for legal and routine business reasons.

We share personal information among our affiliates and business units when we believe it will enhance the services we can provide, but only in circumstances where such sharing conforms to law, any applicable confidentiality agreements, and our policies and practices.

We may disclose information we have about you as required or permitted by law. For example, we may share information with regulatory authorities and law enforcement officials when we believe in good faith that such disclosure is necessary to comply with legal requirements. We may share information with third parties where appropriate to protect against fraud or verify or enforce our terms of use, our other rights, or other applicable policies.

From time to time, we enter into agreements with other companies to provide services to us, or to make services and products available to you. Under these agreements, these companies may receive your personal information, but they must safeguard this information, and they may only use it for those purposes we specify.

We may share your personal information with any person or entity if we have your consent to do so.

We may transmit, transfer or process information to, or through, any country in the world, as we deem necessary, appropriate or consistent with legal or regulatory obligations.

As a global company, we strive to provide you with access to the highest-quality financial products and services wherever you are. To do this, we may share your personal information among members of the GrupoFinanciere family of companies or service providers that may be located outside your home country. Although the data protection laws of these countries may be less stringent than those in your own, GrupoFinanciere will take appropriate steps to ensure your personal information is handled as described in this Online Privacy Policy.

We provide you with relevant and appropriate choices regarding the sharing of personal information.

We may give you choices regarding the sharing of personal information with affiliates and third parties. Choices you have about the sharing of your personal information will be described in the privacy policies or notices you receive in connection with the financial products or services you obtain from us.

We offer you the opportunity to access and correct your information on file with us.

Keeping your account information up-to-date is very important. You may review or update certain account information by logging in and accessing the relevent section. If you cannot change the incorrect information online, or you prefer to request changes offline, please contact your GrupoFinanciere representative using the contact information listed on your account statements, records or other account materials.

We respect your decisions about the collection of personal information related to your online activities over time and across different websites for advertising purposes.

GrupoFinanciere does not allow unaffiliated third parties to collect personal information about your online activities when you visit our online services. Nor do we use personal information collected across non-affiliated websites for the purpose of serving you advertising related to your browsing behavior. If we engage in this practice in the future, we will provide appropriate notice and choice so that you may opt out of the practice.

We tell you when our privacy policies and practices change.

We may change this Online Privacy Policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new "Last Updated" date. All changes will become effective when posted unless indicated otherwise.

Last updated: June 1, 2014

Terms of Use

AS USED HEREIN, THE TERMS "YOU" AND "USER" SHALL MEAN ANY VISITOR TO THE WEBSITE.

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY. BY ACCESSING THIS WEBSITE YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS BELOW. THESE TERMS AND CONDITIONS ARE SUBJECT TO CHANGE WITHOUT NOTICE, FROM TIME TO TIME IN OUR SOLE DISCRETION. WE WILL NOTIFY YOU OF AMENDMENTS TO THESE TERMS AND CONDITIONS BY POSTING THEM TO THIS WEBSITE. IF YOU DO NOT AGREE WITH THESE TERMS AND CONDITIONS, PLEASE DO NOT ACCESS THIS WEBSITE.

You are strictly prohibited from unauthorized use of our systems or this website, including but not limited to unauthorized entry into our systems, misuse of passwords, or misuse of any information posted to this Website.

You acknowledge that we may disclose and transfer any information that you provide through this Website to (i) any company within the GrupoFinanciere companies, its affiliates, agents or information providers; (ii) to any other person or entity with your consent; or (iii) if we have a right or duty to disclose or are permitted or compelled to so disclose such information by law. You consent to the transmission, transfer or processing of such information to, or through, any country in the world, as we deem necessary or appropriate, and by using and providing information through this Website you agree to such transfers.

Use of this Website may be monitored, tracked and recorded. Anyone using this Website expressly consents to such monitoring, tracking and recording. You are responsible for being familiar with the current version of these Terms and Conditions posted on the Website during each session.

Copyright notices

The works of authorship contained in this Website, including but not limited to all design, text, sound recordings, and images, are owned, except as otherwise expressly stated, by GrupoFinanciere or one of its subsidiaries. Except as otherwise expressly stated herein, they may not be copied, transmitted, displayed, performed, distributed (for compensation or otherwise), licensed, altered, framed, stored for subsequent use, or otherwise used in whole or in part in any manner without the owner's prior written consent, except to the extent permitted and then, only with notices of the owner's proprietary rights. Except for any third party exchange data, you may download information and print out a copy for your personal use, so long as you do not remove any copyright or other notice as may be contained in information, as downloaded.

Website content and materials

The information on this Website is for information purposes only. It is believed to be reliable, but we do not warrant its completeness, timeliness or accuracy. User accesses, uses, and relies upon such content at User's own risk. Please seek the advice of professionals as necessary regarding the evaluation of any content on this Website. The information on this Website is not intended as an offer or solicitation for the purchase of any stock, any other security or any financial instrument or to provide any investment service or investment advice in any jurisdiction.

Securities, annuities swaps and insurance products are not bank deposits and are not insured nor are they obligations of, nor insured or guaranteed by, GrupoFinanciere. or any of its subsidiaries or affiliates. Securities annuities, swaps and futures involve investment risks, including the possible loss of value. The information and materials contained in this Website - and the terms and conditions of the access to and use of such information and materials - are subject to change without notice. Products and services described, as well as associated fees, charges, interest rates, and balance requirements may differ among geographic locations. Not all products and services are offered at all locations. Your eligibility for particular products or services is subject to final GrupoFinanciere determination and acceptance.

Some of our other websites or pages within this Website contain supplemental terms and conditions and additional disclosures and disclaimers, which are in addition to these terms and conditions, disclosures and disclaimers. In the event of a conflict, the supplemental terms and conditions and additional disclosures and disclaimers will govern for those sections or pages.

Materials and information posted on the Website may be printed for your use, provided, however, that third party exchange data, if any, may not be downloaded, printed or redistributed for any purposes whatsoever. Materials and information posted on the Website may not be duplicated, copied, re-disseminated or re-distributed to any other person or entity. Re-dissemination and re-distribution includes, without limitation, making any such materials and information available via the Internet or via any other electronic means of access.

All GrupoFinanciere research is subject to a disclaimer included in such research. Any material excerpted or summarized from a research report is subject to the terms of the disclaimer. The information on the Website, including research, is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Any investments discussed on the Website may fluctuate in price or value. Investors may get back less than they invested. Changes in rates of exchange may have an adverse effect on the value of investments.

The value of the securities or financial instruments mentioned herein (including the income derived there from) may be adversely affected by changes in market prices and exchange rates, the imposition of taxes and other factors. Prices, opinions and estimates reflect our judgment on the date of original publication and are subject to change at any time without notice. Information concerning past performance is not necessarily a guide to future performance.

You agree that (i) you will not engage in any activities related to this Website that are contrary to applicable law, regulation or the terms of any agreements you have with us, and (ii) in circumstances where locations of this Website require identification for access, you will establish commercially reasonable security procedures and controls to limit access to your password or other identifying information to authorized individuals. You agree that you will not use any robot, spider, other automatic device or manual process to monitor or copy our web pages, data or the content contained herein or for any other unauthorized purpose without our prior expressed written permission.

WE OR OUR SUPPLIERS MAY DISCONTINUE OR MAKE CHANGES IN THE INFORMATION, PRODUCTS OR SERVICES DESCRIBED HEREIN AT ANY TIME WITHOUT PRIOR NOTICE TO YOU AND WITHOUT ANY LIABILITY TO YOU. ANY DATED INFORMATION IS PUBLISHED AS OF ITS DATE ONLY OR, IF NO DATE IS STATED, THE DATE OF FIRST POSTING. WE DO NOT UNDERTAKE ANY OBLIGATION OR RESPONSIBILITY TO UPDATE OR AMEND ANY INFORMATION ON THIS WEBSITE. WE RESERVE THE RIGHT TO TERMINATE ANY OR ALL WEBSITE OFFERINGS OR TRANSMISSIONS WITHOUT PRIOR NOTICE TO YOU. FURTHERMORE, NO DISTRIBUTION OR SOLICITATION IS MADE BY US TO ANY PERSON TO USE THIS WEBSITE OR THE INFORMATION, PRODUCTS OR SERVICES IN JURISDICTIONS WHERE THE PROVISION OF THIS WEBSITE AND SUCH INFORMATION, PRODUCTS OR SERVICES IS PROHIBITED BY LAW.

Suitability and Appropriateness

Securities or financial instruments mentioned in the Website may not be suitable or appropriate for all investors or in all geographical areas. Your particular needs, investment objectives and financial situation were not taken into account in the preparation of this Website and the materials contained herein. You must make your own independent decisions regarding any securities or financial instruments mentioned herein. The fact that GrupoFinanciere has made available to you through the Website, investment opinions and other information constitutes neither a recommendation that you enter into a particular transaction nor a representation that any financial instrument is suitable or appropriate for you. You should consider whether an investment strategy or the purchase or sale of any product is appropriate for you in the light of your particular investment needs, objectives and financial circumstances.

Potential Disruption of Service

You shall be responsible for obtaining and maintaining all telephone, computer hardware, software, and other equipment needed to access and use this Website. Access to this Website may from time to time be unavailable, delayed, limited or slowed due to, among other things:

hardware failure, including among other things, failures of computers (including your own computer), servers, networks, telecommunication lines and connections, and other electronic and mechanical equipment;

software failure, including among other things, bugs, errors, viruses, configuration problems, incompatibility of systems, utilities or applications, the operation of firewalls or screening programs, unreadable codes, or irregularities within particular documents or other content;

interruption (whether partial or total) of power supplies or other utility of service;

strike or other stoppage (whether partial or total) of labor;

governmental or regulatory restrictions, exchange rulings, court or tribunal orders or other human intervention; or

any other cause (whether similar or dissimilar to any of the foregoing) whatsoever beyond our control.

If access to this Website is unavailable, delayed or limited, or if this Website does not operate quickly and efficiently, you may be unable to transmit your instructions for transactions and other matters, or such instructions may not be promptly executed or you may be unable to retrieve information on a timely basis. If your operations are dependent on such communications with us, and such communications are disrupted or delayed, you may suffer losses. GrupoFinanciere will not be liable for any such loss.

Links to other sites

Links to unaffiliated websites are provided solely as pointers to information on topics that may be useful to users of this Website, and we have no control over the content on such unaffiliated websites. If you choose to link to a website we do not control, we make no warranties, either express or implied, concerning your use of or inability to use such site, the content of such site, including the accuracy, completeness, reliability, or suitability thereof for any particular purpose, nor do we warrant that such site or content is free from any claims of copyright, trademark, or other infringement of the rights of third parties or that such site or content is devoid of viruses or other contamination. We do not guarantee the authenticity of documents on the Internet. Links to unaffiliated sites do not imply any endorsement of or responsibility for the opinions, ideas, products, information, or services offered at such sites, or any representation regarding the content at such sites and we expressly disclaim any such endorsement or representation. In addition, these third party websites may have a privacy policy or security practices different from this Website so it is important to read the policies of those sites before sharing your personal information.

LIMITATION OF LIABILITY

BECAUSE OF THE POSSIBILITY OF HUMAN AND MECHANICAL ERROR AS WELL AS OTHER FACTORS, THE WEBSITE (INCLUDING ALL INFORMATION AND MATERIALS CONTAINED ON THE WEBSITE) IS PROVIDED "AS IS" AND "AS AVAILABLE." WE, OUR AFFILIATES, AND ANY THIRD PARTY DATA PROVIDERS:

ARE NOT PROVIDING ANY WARRANTIES AND REPRESENTATIONS REGARDING THE WEBSITE;

DISCLAIM ALL WARRANTIES AND REPRESENTATIONS OF ANY KIND WITH REGARD TO THE WEBSITE, INCLUDING ANY IMPLIED WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF THIRD PARTY RIGHTS, FREEDOM FROM VIRUSES OR OTHER HARMFUL CODE, OR FITNESS FOR A PARTICULAR PURPOSE;

DO NOT WARRANT THE ACCURACY, ADEQUACY, OR COMPLETENESS OF THE INFORMATION AND MATERIALS CONTAINED ON THE WEBSITE AND EXPRESSLY DISCLAIMS LIABILITY FOR ERRORS OR OMISSIONS IN THE MATERIALS AND INFORMATION; AND

WILL NOT BE LIABLE FOR ANY DELAY, DIFFICULTY IN USE, COMPUTER VIRUSES, MALICIOUS CODE OR OTHER DEFECT IN THIS WEBSITE, ANY INCOMPATIBILITY BETWEEN THE WEBSITE AND THE USER'S FILES AND THE USER'S BROWSER OR OTHER SITE ACCESSING PROGRAM, OR ANY OTHER PROBLEMS EXPERIENCED BY THE USER DUE TO CAUSES BEYOND OUR CONTROL.

NO LICENSE TO THE USER IS IMPLIED IN THESE DISCLAIMERS. NOTHING HEREIN SHALL BE CONSTRUED AS LIMITING OR REDUCING OUR RESPONSIBILITIES AND OBLIGATIONS TO CLIENTS IN ACCORDANCE WITH APPLICABLE LAWS AND REGULATIONS..

UNDER NO CIRCUMSTANCES WILL WE BE LIABLE FOR ANY LOST PROFITS, LOST OPPORTUNITY OR ANY INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES ARISING OUT OF ANY USE OF OR INABILITY TO USE THE WEBSITE OR ANY PORTION THEREOF, REGARDLESS OF WHETHER WE HAVE BEEN APPRISED OF THE LIKELIHOOD OF SUCH DAMAGES OCCURRING AND REGARDLESS OF THE FORM OF ACTION, WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR OTHERWISE.

Enforceability and Governing Law

In the event any of the terms or provisions of these Terms and Conditions shall be held to be unenforceable, the remaining terms and provisions shall be unimpaired and the unenforceable term or provision shall be replaced by such enforceable term or provision as comes closest to the intention underlying the unenforceable term or provision.

Cookies Policy

1. What are Cookies?

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can recognize you when you revisit and remember certain information about you. This can include which pages you have visited, choices you have made from menus, any specific information you have entered into forms and the time and date of your visit.

2. Types of Cookies

There are two main types of cookies:

Session cookies: these are temporary cookies that expire at the end of a browser session; that is, when you leave the site. Session cookies allow the website to recognize you as you navigate between pages during a single browser session and allow you to use the website most efficiently. For example, session cookies enable a website to remember that a user has placed items in an online shopping basket.

Persistent cookies: in contrast to session cookies, persistent cookies are stored on your equipment between browsing sessions until expiry or deletion. They therefore enable the website to "recognize" you on your return, remember your preferences, and tailor services to you.

In addition to session cookies and persistent cookies, there may be other cookies which are set by the website which you have chosen to visit, such as this website, in order to provide us or third parties with information.

3. Our use of Cookies

We currently use, and may use in the future, the following types of cookies on this website.

We use session cookies to:

Help us maintain security and verify your details whilst you use the website as you navigate from page to page, which enables you to avoid having to re-enter your details each time you enter a new page.

We use persistent cookies to:

Help us recognize you as a unique user when you return to our website so that you do not have to input your details multiple times as you move between our pages or services

Remember how you have customized your use of this site, such as your preferred currency and time zone

Collect and compile anonymous, aggregated information for statistical and evaluation purposes to help us understand how users use the website and help us improve the structure of our website.

Many cookies are designed to give you optimal usage of the web. For example, we use cookies to enable you to improve your user experience when using our website, e.g. a cookie which recognizes if your browser supports specific technology features. This helps, for example, in enabling web pages to be loaded more quickly when you request the download of a large file.

In addition to cookies which send information to us, we also use cookies which collect information and send it to third parties. An example of this is Google Analytics. We use Google Analytics to help collect and compile information like the number of visitors to the site, where visitors have come to the site from and the pages they visited. Visit Google's site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. Where this site allows such cookies to be set or you access other websites from this site using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours.

As with first party cookies, you are able to block third party cookies through your browser settings.

Some of our cookies may collect and store your personal information, such as your name or email address. We are committed to respecting and protecting your privacy and will ensure that all personal information collected by us is kept and treated in accordance with our privacy policy. A link to this policy is available within the footer of this portal or alternatively at our website.

4. Refusing Cookies on this Site

Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing your internet software browsing settings. It may also be possible to configure your browser settings to enable acceptance of specific cookies or to notify you each time a new cookie is about to be stored on your computer enabling you to decide whether to accept or reject the cookie. To manage your use of cookies there are various resources available to you, for example the "Help" section on your browser may assist you. You can also disable or delete the stored data used by technology similar to cookies, such as Local Shared Objects or Flash cookies, by managing your browser's "add-on settings" or visiting the website of its manufacturer. As our cookies allow you to access some of our website's features we recommend that you leave cookies enabled. Otherwise, if cookies are disabled, it may mean that you experience reduced functionality or will be prevented from using this site altogether.

Conflicts of Interest Policy

GrupoFinanciere conducts its business according to the principle that it must manage conflicts of interest fairly, both between itself and its clients and between one client and another.